This Policy was last updated on November 1, 2018.
We are committed to protecting the privacy and security of the personal information we receive or collect from you. We also believe in transparency and are committed to informing you about how we treat your personal information.
Who is Responsible for your Personal Information?
Populy is responsible for implementing the applicable data protection principles and for safeguarding the personal information you provide to us through our Website. If you are a user in in the European Union (the “EU”) or European Economic Area (“EEA”), for purposes of the EU General Data Protection Regulation, 2016/679 (the “GDPR”), Populy acts as a data processor with respect to the personal information we collect from you via our Website when you are voting or using the Website in connection with a particular event. In such instances, Populy is a data processor for its data controller customers who operate the event in connection with which end-users are voting or using the Website. Populy acts as a data controller with respect to the personal information we collect from you via cookies and other similar technologies, which are discussed in our Cookies and Similar Technologies Policy [https://www.populy.io/legal/cookies].
What information do we collect?
We may collect and process the following personal information from you for the purposes set forth below:
||Types of Data and Purpose
||When you visit our Website or request our services, we may ask you for your name, address, telephone number, email address, or other contact details in order to respond to your request or inquiry.
|User Account Information
||In order to access and use certain features of our Website, you must first complete a registration. When you create an account, we collect your contact information, other identity information (e.g., age, date of birth), other demographic information (location), username and password, and other registration information, including payment information. This information is necessary to enable us to provide you the account you have requested and to maintain the account and your profile. You may update your account information by editing the information associated with your account.
||In connection with our services, we will ask customers (e.g. event organizers) to provide their name, email address, and telephone number during the sign-up process.
||In connection with our services, we will ask users (e.g. judges and competitors) to provide their name, email address, and telephone number during the sign-up process. This information may be collected prior to an event and provided to the event organizer(s) or collected via volunteers during in-person registration.
||When you seek services from us in the course of contractual or customer relationships between you, and/or your organization, and us, we collect business contact information and other personal information in order to provide you with the services you have requested.
||When you use our Website, we may collect information about your use of our Website, including your interaction with advertising and analytics services on the Website, in order to (a) serve you the content and functionality you request, and (b) maintain the privacy and security of the Website and services. Location information collected may include your Internet Protocol (IP) address or unique device identifier.
|Cookies and Similar Technologies
Please see our Cookies and Similar Technologies Policy [https://www.populy.io/legal/cookies] for more information. If you choose to disable cookies and similar technologies, some areas and features of the Website may not work properly.
||When you visit our Website, we automatically collect information from your browser or your mobile device, which includes the date and time of your visit, your Internet Protocol (IP) address or unique device identifier, your browser type, cookies and data about which pages you visit in order to allow us to operate and provide the Website and our services. This information is used to understand how you interact with the Website and to provide you with advertising and a more personalized experience. To learn more about our collection of technical data, please visit our Cookies and Similar Technologies Policy [https://www.populy.io/legal/cookies].
||If you receive email communications from us, we may use certain tools to capture data related to if/when you open our message, click on any links or banners it contains. Other information collected through this email tracking feature includes: your email address, the date and time of your “click” on the email, a message number, the name of the list from which the message was sent, a tracking URL number, and a destination page. We use this information to enhance our marketing efforts. We do not sell or distribute this information to third parties.
|Feedback / Support / Inquiries
||If you provide us with feedback or contact us for support or to ask us questions, we will collect your name, address, telephone number, email address, and other information needed to respond to your feedback, or request for support, or to answer your question.
||When you sign up for one of our mailing lists, we collect your contact information, including your email address.
|Sensitive Personal Information
||Our customers may configure our Services to collect information regarding your racial or ethnic origin, gender, citizenship status, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health information, financial information, or data concerning your sex life or sexual orientation. We will collect this sensitive personal information with your express consent or as otherwise permitted by applicable law.
||When you communicate with us, we may retain your communications in order to process and respond to them, as well as to improve our Services. We may use your email address to communicate with you about our Services or send you periodic emails if you decide to opt-in to any of our mailing lists.
|Financial and Payment Information
||If you choose to purchase services from us, we may collect your name, address, telephone number, bank account number, bank routing information, and other data necessary to process payments, including credit card numbers, security codes, expiration dates, and other related billing information. By submitting your payment card information, you expressly consent to the sharing of your information with third-party payment processers and other third-party services (including but not limited to vendors who provide fraud detection services to us and other third parties). We do not store your payment information.
How Do We Use Your Personal Information?
When applicable, we process your personal data in accordance with the instructions from our data controller customers. In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly-available sources.
We collect and use the types of personal information listed above in an effort to improve your experience on the Website, to provide services to you, and to communicate with you about the information you have requested. We may also use personal information to help target specific offers to you and to help us develop and improve our Website and services. Additionally, we may use your personal information in the following ways:
- To provide you with the services you have requested and to manage our relationship with you, including administering your account, processing payments, accounting, auditing, billing and collection and taking other steps necessary to the performance of our business relationship with you;
- To present and improve Website’s content and functionality;
- To personalize your experience (Your information helps us to better respond to your individual needs.)
- To improve customer service (Your information helps us to more effectively respond to your customer service requests and support needs.)
- To respond to visitor, subscriber, and customer inquiries;
- To determine user interests, needs, and preferences;
- To provide notice of changes to our Website or the services and products we offer or provide through them;
- To deliver services and products to you and honor our contract [https://www.populy.io/legal/tos] with you, including, but not limited to, providing you with access to publications such as our newsletter;
- To conduct research and analysis;
- To develop new products and services;
- To manage and maintain the security of our Website and services;
- To administer a contest, promotion, survey or other site feature (We may periodically run a contest, sweepstakes, or survey relating to our website. When we run a contest or sweepstakes relating to our website, it will be accompanied by a set of rules. The rules for each contest/sweepstakes will specify how the information gathered from you for entry will be used and disclosed.)
- To market our services and products to you. We will only provide you with marketing-related information after you have, where legally required to do so, opted in to receive those communications and having provided you with the opportunity to opt-out of such communications at any time. We do not sell or distribute this information to third parties or use it for any other purpose;
- To send periodic emails including information and updates pertaining to your order. Populy will also use your contact information to respond to your requests or inquiries. Populy may use your contact information to send you information about our company, including our affiliates, or our products or services, or to contact you when necessary. You may opt out of receiving emails by choosing to opt out on our website.)
Is entry of Personal Information required?
You may choose not to provide us with any Personal Information. Even if you choose not to provide any Personal Information, you may still access and use much of the website. However, you will not be able to access any portions of the website that require your Personal Information. Some pages on the website may give you the option of providing certain of your Personal Information about yourself. If you want to change any information about yourself that you have submitted, you may update your profile online.
Sharing and Disclosing of Your Personal Information
When applicable, we process your personal data in accordance with the instructions from our data controller clients. When we are acting as a data controller and where the GDPR does not apply, we may share your information in the following contexts. If we are acting as a data processor, disclosures in the following contexts will be limited in accordance with the instructions form the data controller.
|Subsidiaries and Acquisitions
||We may share your personal information with our corporate subsidiaries and affiliates. In addition, we may disclose your personal information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our company assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our website users is among the assets transferred. For example, if another company acquires us, we will share your personal information with that company.
|Disclosures With Your Consent
||When we are acting as a data processor, we may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Policy. We will only disclose your personal information in this context with your consent.
|Disclosures Without Your Consent
||We may disclose your personal information in response to subpoenas, warrants, court orders or other legal process, or to comply with relevant laws. We may also share your personal information in order to establish or exercise our legal rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property or a violation of our Terms of Service.
||You may consent through account registrations to having your contact information shared with other account holders.
||We may provide personal information about you to our customers in connection with our services and they may offer products and services specifically requested by you.
||We may share your personal information with our service providers. Among other things, service providers may help us to administer the Website, support our provision of services requested by you, provide technical support; send marketing, promotions and communications to you about our services; provide payment processing; and assist with other legitimate purposes permitted by law.
||We may disclose aggregated information about our users, and information that does not identify any specific individual, such as groupings of demographic data and customer preferences, for new product and marketing development.
How Long Do We Store Your Personal Information?
Populy will retain your personal information as needed to fulfill the purposes for which it was collected. We will retain and use your personal information as long as necessary to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our services, and to enforce our agreements. When applicable, we store your personal data in accordance with the instructions from our data controller clients.
When we no longer have a purpose to retain your personal information, we will securely destroy your personal information in accordance with applicable law and our policies. We take reasonable steps to delete the personal information we collect if your registration to use our Website lapses and you opt out of receiving further communications from us, or if you ask us to delete your information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. We may retain and use anonymous and aggregated information for performance reporting, benchmarking, and analytic purposes and for product and service improvement.
If you no longer wish to receive communications from us via email, you may opt-out by contacting us at email@example.com and providing your full name, mailing address, phone number and email address so that we may identify you in the opt-out process. Once we receive your instruction, we will promptly take corrective action.
How do we protect your information?
We have put in place reasonable and appropriate security measures to protect the personal information that you share with us from being accidentally lost, used or accessed in an unauthorized manner, altered or disclosed. We use a secure server. We do not store or save your financial information. From time to time, we review our security procedures to consider appropriate new technology and methods. While our security measures seek to protect your personal information in our possession, no security system is perfect, and we cannot promise that your personal information will remain absolutely secure in all circumstances.
The safety and security of your personal information also depends on you. Where you use a password for access to restricted parts of the Website, you are responsible for keeping the password confidential. Do not share your password with anyone.
If a security breach causes an unauthorized intrusion into our Website or systems that compromises your data, we will notify you and any applicable regulator when we are required to do so by applicable law and by our agreements with our data controller customers.
Updating Your Personal Information
If any of the personal information you have provided to us changes, please let us know. For instance, if your email changes, you may wish to cancel any request you have made of us, or if you become aware of inaccurate personal information about you, you may use the “Contact Us” details provided at the end of this Policy to update your information.
We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.
Your Rights To Access And Control Your Personal Information
Please use the Contact Us details at the end of this Policy to exercise your rights and choices under this Policy. If you would like to manage, change, limit or delete your personal information or you no longer want to receive any email, postal mail, or telephone contact from us or our affiliates in the future, such requests may be submitted via the Contact Us details at the end of this Policy. If you are exercising a right that is the responsibility of our data controller customers, we will direct you to contact the appropriate data controller who is responsible for responding to your request.
Right of Access. If required by law (e.g., under the GDPR), upon request, we will grant reasonable access to the personal information that we hold about you.
Accuracy. Our goal is to keep your personal information accurate, current and complete. Please contact us if you believe your information is not accurate or if it changes.
Right to Object. In certain circumstances, as permitted under applicable law, you have the right to object to processing of your personal information and to ask us to erase or restrict our use of your personal information. If you would like us to stop using your personal information, please contact us, and we will let you know if are able to agree to your request.
Right to Erasure and Deletion of Your Personal Information. You may have a legal right (for instance, if you are located in the EU or EEA under the GDPR) to request that we delete your personal information when it is no longer necessary for the purposes for which it was collected, or when, among other things, your personal information has been unlawfully processed. All deletion requests should be sent to the address noted in the Contact Us section of this Policy.
We may decide to delete your personal information if we believe it is incomplete, inaccurate or that our continued storage of your personal information is contrary to our legal obligations or business objectives. When we delete personal information, it will be removed from our active servers and databases and our Website, but it may remain in our archives when it is not practical or possible to delete it. We may also retain your personal information as needed to comply with our legal obligations, resolve disputes, or enforce any agreements.
Right to Withdraw Consent. If you have provided your consent to the collection, processing and transfer of your personal information, you have the right to fully or partially withdraw your consent. To withdraw your consent, please notify us using the information in the Contact Us section of this Policy and you may follow opt-out links on any marketing communications sent to you.
Once we have received notice that you have withdrawn your consent, in whole or in part, we will no longer process your information for the purpose(s) to which you originally consented and have since withdrawn unless there are compelling legitimate grounds for further processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
Withdrawal of consent to receive marketing communications will not affect the processing of personal information for the provision of our services.
Right to Complain. If you believe that your rights relating to your personal information have been violated, you have a right to lodge a complaint with the applicable enforcement authority, or seek a remedy through the courts. You may also lodge a complaint with us by contacting us using the information provided in the Contact Us section of this Policy.
Online Tracking. We do not currently recognize browser settings or signals of tracking preferences, which may include “Do Not Track” instructions. “Do Not Track” is a web browser setting that seeks to disable the tracking of individual users’ browsing activities. It is a standard that is currently under development. As it is not yet finalized, we adhere to the standards set out in this Policy and do not currently respond to “Do Not Track” signals on our Website or on third-party websites or online services where we may collect information.
California Residents. Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. At present, Populy does not share your personal information with third parties. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of our site may make any changes to their information at any time by contacting us at firstname.lastname@example.org.
European Union or European Economic Area Residents. If you are located in the EU or EEA and believe we have not processed your personal information in accordance with applicable provisions of the EU GDPR, we encourage you to contact us at email@example.com. You may lodge a complaint with your local data protection or supervisory authority.
Cross-Border Transfers of Personal Information
Populy is located and established in the United States and, therefore, your personal information may be transferred to, stored, or processed in the United States. While the data protection, privacy and other laws of the United States might not be as comprehensive as those in your country, we take necessary and appropriate steps to protect the privacy and security of your personal information. By using the Website or requesting services from us, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in the United States and those third parties with whom we share it as described in this Policy.
Children’s Online Privacy Protection Act Compliance
The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the internet. Our Website and services are not directed to children aged 18 or younger, nor is information knowingly collected from children under the age of 18. No one under the age of 18 may access, browse, or use the Website or provide any information to or on the Website. If you are under 18, please do not use or provide any information on the Website. If we learn that we have collected or received personal information from a child under the age of 18 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it.
For more information about COPPA, please visit the Federal Trade Commission's website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.
Links to Other Web Pages and Your Privacy
The website may contain links to, and media and other content from, third-party websites. These links are to external websites and third parties with which we have no relationship. Because of the dynamic media capabilities of the Website, it may not be clear to you which links are to the Website and which are to external, third party websites. If you click on an embedded third-party link, you will be redirected away from the Website to the external third-party website. You can check the URL to confirm that you have left this Website.
Populy cannot and does not (i) guarantee the adequacy of the privacy and security practices employed by or the content and media provided by any third parties or their websites, (ii) control third parties’ independent collection or use or your personal information, or (iii) endorse any third party information, products, services or websites that may be reached through embedded links on this Website.
In writing: Populy Voting Systems 800 Peachtree St NE Unit 2203 Atlanta GA 30308
By phone: +1-855-343-8683
By email: firstname.lastname@example.org